Overview of the NM Air Quality – Ozone Precursor Pollutants Regulation
NMED OpenEnviro Map of Methane Hotspots (Red, Orange, Yellow are higher emissions)
My previous post was on tropospheric ozone, a precursor to this discussion on methane emission regulations and explanation why the regulations title is about ozone. The New Mexico Ozone Precursor Pollutants regulation is the New Mexico Environment Department (NMED) component of a two part state regulation developed from the NM Methane Advisory Panel. The NM Energy, Minerals and Natural Resources Department (EMNRD) co-developed the Natural Gas Waste Rules establishing the other regulation for reporting production and disposition of gas from wells.
The NMED Ozone Precursor regulation’s goal is to establish emission standards for volatile organic compounds (VOC) and nitrogen oxides (NOx) for oil and gas production, processing, compression, and transmission sources. Not that government regulations are hard to read, but buried in the four and a half pages of definitions is a key component of the regulation called “Potential to emit (PTE)”. Any source of VOC or NOx gasses from a source that by physical or operational design can emit an air pollutant falls in the PTE category. Owners and operators of a crude oil or natural gas production and processing equipment have to determine if their equipment has the Potential to Emit, and if so they must keep records of regular inspections and operational and accidental emissions from those sources.
This regulation is directed entirely at the oil and gas industries and is limited to those counties falling in the Permian and the San Juan Basin’s with the exception of Dona Ana and Valencia county containing population centers and NG transmission centers. Note: NG distribution is not covered by the regulation. The types of gas sources regulated beyond those self-defined as PTE’s and having their own sections in the regulation are:
Stationary Engines and Turbines
Centrifugal Compressor Seals
Control Devices and Closed Vent Systems (including flares, ECD’ and TO’s)
Equipment Leaks and Fugitive Emissions
Natural Gas Well Liquid Unloading
Natural gas-fired Heaters greater than 20 MMBtu/hr
Hydrocarbon Liquid Transfers
Pig Launching and Receiving
Pneumatic Controllers and Pumps
Well Workovers and retrofits
Produced Water Units and Flowback Vessels
Each of these sources of VOC’s and NOx gasses must be inspected and reported to the NMED. The methods and instrumentation to accomplish the inspections is contained within each section, though overall every subsection must to generate a Compliance Database Report (CDR) of the inspection findings. The equipment identification, location, make, and model are all recorded along with the measurement. Although onerous, there are compliance database and/or maintenance software tools that every reputable operation should already be utilizing to track their equipment conditions. (A quick search on Computerized Maintenance Management Systems should result in numerous hits). Every aspect of the regulation has a two year phase in period. Industry has several opportunities to develop their own processes to meet the reporting requirements and can submit them for review and approval. With the introduction of the NMED and ENMRD policies, time will tell if NM emission hot spots can be controlled.